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OMB circular A-133:
Uniform Guidance (2 CFR 200):
The grant period usually does not match with the term of a graduate student or a post-doc exactly. Therefore, if one allows institution to approve the budget re-allocation between graduate students and post-docs, instead of seeking approval from funding agency, that will make research go more smoothly based on the need of individual project.
AAU, COGR, and APLU recommend that OMB require all Federal agencies subject to OSTP’s 2013 policy memorandum, “Increasing Access to the Results of Federally Funded Scientific Research,” to harmonize the procedures by which extramural grantees submit final peer-reviewed manuscripts or final published documents and data to the agencies’ public access repositories. We believe that this harmonization process may most effectively ...more »
Institutions must manage data for multiple highly complex loan, grant, and work study sources for Title IV aid. Creating uniform interfaces and navigation across existing systems would assist the administrators responsible for maintaining data in multiple portals.
In at least some areas of NSF there is a two-stage proposal process: A short preliminary proposal goes to an initial screening. If it passes that initial screening then a full proposal must be written. I would propose that NEH adopt this process as well. Given the intense competition for NEH grants, with a success rate hovering around 15%, although for the most competitive grants it’s about 6%. Writing grants is a ...more »
Currently Modified Total Direct Cost (MTDC) only allows inclusion of subcontracts up to the first $25,000 of each subaward or subcontract (regardless of the period of performance of the subawards and subcontracts under the award). We suggest increasing this to the first $50,000.
Harmonize Requirements and Standardized Collection of Non-Financial Training Prior to Issuance of an Award - Non-Financial Investigator training requirements (e.g. Financial Conflict of Interest, Responsible Conduct of Research, Research with Human Subjects), are convoluted because acceptable subject matter and timelines for completion vary by agency. Non-financial training requirements should be harmonized to reduce ...more »
2. Eliminate Two Layer IRB and IACUC Review of Human and Vertebrate Animal Research - Institutions receiving federal funds for research with human subjects or vertebrate animals are required to maintain a Federal-wide Assurance (FWA) or Animal Welfare Assurance (AWA) with the DHHS Office of Human Research Protections (OHRP) or Office of Laboratory Animal Welfare (OLAW), respectively. Institutions thereby accept the responsibility ...more »
1. Achieve a true single audit. IHEs are still subject to multiple audits of their individual programs and compliance processes, despite the Single Audit Act of 1984, OMB Circular A-133 and 2CFR-200 Uniform Guidance which mandate single audits for non-federal entities that receive federal funding. The University is subject to a major compliance audit, desk audits and program audits each year.
1. Achieve a true single audit. IHEs are still subject to multiple audits of their individual programs and compliance processes, despite the Single Audit Act of 1984, OMB Circular A-133 and 2CFR-200 Uniform Guidance which mandate single audits for non-federal entities that receive federal funding. The University is subject to a major compliance audit, desk audits and program audits each year.
I spend more time figuring out what I have to report than actually reporting it. If the process could be streamlined with fillable forms, this would make it much easier!
For each person paid from the grant who worked >160 hours (1 person month) during the grant year, there must be a Commons ID (including the completion of Personal Profile Information). There also needs to be information about the total number of hours each person worked on the grant during grant year so that person months can be calculated. This information is required for undergraduate who may be paid hourly as student ...more »
The requirement to list PubMed Central ID #s is a HUGE time and effort burden for research administrators. That is the #1 requirement I would change. There must be other ways to track compliance with the Public Access Policy.